The Policies & Procedures (P&P) Builder, a module of NASFAA’s Compliance Engine, guides you step-by-step through the creation of a centralized, accessible policies and procedures manual. Due to the timing of the release of the P&P Builder template each year, the U.S. Department of Education (ED) may provide new guidance which affects the existing template. In response, updates will be made to the P&P Builder template.

New regulations, effective July 1, 2026, have been released with some aspects which schools may opt to early implement starting on February 3, 2025. Regulations subject to early implementation have been summarized. The new regulatory references will be included in the update to the P&P Builder for the 2025-26 award year, but if early implementation is utilized, it must be included in your policies and procedures now.  

January 3, 2025, Federal Register - Program Integrity and Institutional Quality: Distance Education and Return of Title IV, HEA Funds

1. There is now a new optional exemption from performing an return of Title IV funds (R2T4) calculation for schools who do the following:

2. Treat students as if they never began attendance, 

3. Return all Title IV aid, 

4. Refund all institutional chargers for the payment period or period of enrollment, and

5. Write off any balance due for the payment period or period of enrollment for students who withdrew 

ED understands that this will affect how enrollment is reported to the National Student Loan Data System (NSLDS), and guidance is forthcoming. 

1. Students enrolled in a Prison Education Program (PEP) may now take a leave of absence (LOA) and return at a different point in the program. This can only be done in situations where their studies were interrupted due to circumstances beyond their control. 

Publication Date: 2/12/2025